SecProbe.io

UNITED STATES
SECURITIES AND EXCHANGE COMMISSION
WASHINGTON, D.C. 20549

       DIVISION OF
CORPORATION FINANCE
       April 21, 2009
 Mail Stop 7010    Mr. James C. Katzaroff, President Advanced Medical Isotope Corporation 8131 W. Grandridge Blvd., Suite 101 Kennewick, WA   99336  Re: Advanced Medical Isotope Corporation
Amendment No. 2 to Registration Statement on Form 10 Filed on April 7, 2009 Form 10-K for the Fiscal Year Ended December 31, 2008
Filed on April 15, 2009
File No. 0-53497
 Dear Mr. Katzaroff:   We have reviewed your filings and have the following additional comments.
Form 10

1. Where we ask for revisions to your disclosu re in the registration statement, please
make similar revisions in the appl icable places in your Form 10-K.

Item 1A.  Risk Factors, page 9

2. Please include your response to comment 5 in our letter dated March 6, 2009 in a
separate risk factor discussing the track record of companies affiliated with UTEK.  We note your disclosure on page 3 that UTEK is in the business of
creating newly formed companies to ac quire a new technology from a university,
medical center, corporation or federal resear ch laboratory and then sell this newly
formed company for securities or cash.  Please also disclose whether any other
public company affiliated with UTEK or Mr. Katzaroff has not achieved profitability, implemented its business plan or is delinquent  in its periodic
reporting obligations.  For example, we not e the disclosure in  UTEK’s Form 10-K
regarding the write down of other invest ments in UTEK’s portfolio, some of
which are public companies.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
April 21, 2009 Page 2  Item 2.  Financial Information, page 16

 Management’s Discussion and Analysis of Fi nancial Condition and Results of Operation,
page 16
 Liquidity and Capital Resources, page 17

3. Please discuss in your liquidity section all material changes in your operating,
investing, and financing cash fl ows as depicted in your statement of cash flows.
See the SEC Interpretive Release No. 33-8350.
 Item 6. Executive Compensation, page 24

 Narrative to Summary Comp ensation Table, page 25

4. We note your response to comment 10 in our letter dated March 6, 2009.  However, the disclosure relating to the co mpensation reflected in the table is still
unclear.  For example, the employment agreement compensation (salary and stock awards) you describe does not reconcile to the amounts reflected in the table.
There is also no description of how the bonus es in the fourth column of the table
were determined.  Please re vise.  If the amounts in the table do not reconcile to
the compensation described in the em ployment agreements, please provide
footnotes to these amounts and explain how the compensation was calculated.
See Item 402(o) of Regulation S-K.
 5. Please describe how your chief executive officer is compensated and whether the company has entered into an employment agreement with him.
 Item 7. Certain Relationships a nd Related Transactions, page 31

6. We note the disclosure in Note 9 to the financial statements that the company has received a loan from two of its major sh areholders.  Please provide the disclosure
required by Item 404 of Re gulation S-K with respect  to this transaction.
 Item 10. Recent Sales of Unregistered Securities, Page 32

7. We note the disclosure in Note 15 to th e financial statements that the company
issued securities in 2009.  Please provid e the disclosure required by Item 701 of
Regulation S-K with respect to these securities.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
April 21, 2009 Page 3  Item 15.  Financial Statements and Exhibits, page 36

 Note 2 – Summary of Significant Accounting Policies, page F-10

8. We note your response to comment 14 in our letter dated March 6, 2009.  You determined that certain unamortized licen se fees and intangible assets were no
longer of value to you and therefore recorded an impairment charge during the
year ended December 31, 2008.  Pleas e consider further expanding your
disclosures to address what consideration you gave as to whether the same factors
that led to these impairment charges also  indicated that you may need to test your
fixed assets for potential impairment.  For any fixed assets which have been tested
for impairment in accordance with SFAS 144, we encourage you to provide qualitative and quantitative descriptions of the material assumptions used to
determine fair value in your impairment analysis and a sensitivity analysis of
those assumptions used based upon reasona bly likely changes.  For any asset
groups for which the carrying value was clos e to the fair value, please consider
disclosing the carrying value of the asset groups.
 Note 8 – Prepaid Expenses Paid with Stock, page F-20

9. We note that you had prepaid expenses in the amount of $75,336 that were
expected to mature in 2009; however, you disclose on the face of your balance
sheet that the current por tion of prepaid expenses paid with stock was $140,579.
In addition, it appears that  prepaid expenses in th e total amount of $172,211 as
disclosed in this footnote is not equal to the total amount of current and non-
current prepaid expenses as disclosed on the face of your bala nce sheet.  Please
advise or revise.

Note 10 – Capital Lease Obligations, page F-20

10. You disclose that you are not in comp liance with the minimum debt service
coverage ratio stipulated in the loan c ovenants.  Accordingly, the lenders could
accelerate the debt.  In light of th is, please help us understand how you
determined that it was appropr iate to classify a portion of this debt as a long term
liability on your balance sheet as of  December 31, 2008.  Refer to EITF 86-30.
 Note 12 – Stockholders’ Equity

 Common Stock Issued for Convertible Debt, page F-26

11. Your statement of cash flows shows proceeds from convertible debt of $218,283 during the year ended December 31, 2008.  Please help us understand how you arrived at this amount given your disclosu res in Note 12 indicat e that you issued

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
April 21, 2009 Page 4
convertible notes for $250,000, $50,000, and $375,000.  Please also clearly
disclose the conversion terms of each of these debt agreements.

12. Please help us better unde rstand your accounting of the convertible promissory
note issued in December 2008.  Specificall y, please help us better understand how
you determined that your shares of comm on stock are not readily convertible to
cash pursuant to paragraph 9(c) of SFAS 133.  Please provide us with a summary of your analysis that you performed that led to this determination.
 Form 10-K for the Fiscal Year Ended December 31, 2008

13. Please amend your Form 10-K to address the comments in this letter.
 Item 5. Market for Registrant’s Common Equity . . ., page 15

14. Please identify the market in which your  common stock is traded. See Item
201(a)(1)(i) of Regulation S-K.
 Item 9A(T). Controls and Procedures, page 22

15. Please provide the disclosure controls and procedures information required by
Item 307 of Regulation S-K.

Management’s Report on Internal Control over Financial Reporting, page 22

16. You disclose that your evaluation was done not using the COSO framework.  Please identify the framework used by management to evaluate the effectiveness of your internal control over financ ial reporting.  See Item 308T(a)(2) of
Regulation S-K.

17. We note your disclosure that there were  material weaknesses in your internal
controls.  Please disclose how the material weakness affects your financial reporting and internal contro ls.  Also disclose the status of the material
weaknesses and whether or not they have  been remediated.  If the material
weaknesses have not been remediated, pl ease tell us when and how the company
expects to do so.  Please tell us in detail  the steps you have taken (or plan to take)
and procedures you implemented (or plan to implement) to correct the material weaknesses you identified.

18. Management is not permitted to conclude th at the registrant's internal control over
financial reporting is effective if there are one or more material weaknesses in
your internal control over financial repor ting.  See Item 308T(a)(3) of Regulation
S-K.  Please revise accordingly.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation
April 21, 2009 Page 5  Signatures, page 32

19. Please revise to reflect that the compa ny’s principal financial officer and its
controller or principal accounting officer have also signed the Form 10-K.  See
General Instruction D to Form 10-K.
 Exhibits 31.1 and 31.2 – Certifications

20. Please file an amendment to the Form 10-K that includes the enti re periodic report
and new, corrected certifications.  Revise  your certifications to reflect the exact
form set forth in Item 601(b)(31) of Regulation S-K.  In that regard, we note the following:

• The identification of the certifying individual at the beginning of each
certification required by Exchange Act Rule  13a-14(a) also includes the title of
the certifying individual.  Revise the identification of the certifying individuals so as not to include su ch individual’s title.
• Since you are not using Form 10-KSB, re place the references to “small business
issuer” in paragraphs 3, 4, 4(a), and 4(d) with “registrant.”
• Since you have elected to include the di sclosure set forth in Item 308T(a) of
Regulation S-K in the Form 10-K, you must add the language “and internal
control over financial reporting (as define d in Exchange Act Rules 13a-15(f) and
15d-15(f)” in paragraph 4.
• Insert the words “and procedures” afte r the words “disclosure controls” in
paragraph 4(c).
• Insert the words “of internal control over financial reporting” after the word
“evaluation” in paragraph 5.
• There are numerous omissions and errors in  paragraph 5(a). Revise to reflect the
exact language in the form.
• Revise Exhibit 31.2 to reflect  the correct name under L. Bruce Jolliff’s signature.

 Please respond to these comments 10 business days, or tell us when you will provide us with a response.  Please provide us with a response letter that keys your
responses to our comments and provides a ny requested information.  Detailed letters
greatly facilitate our review .  Please file your response on EDGAR as a correspondence
file.  Please understand that we may have additional comments after reviewing your
responses to our comments.

Mr. James C. Katzaroff
Advanced Medical Isotope Corporation April 21, 2009 Page 6   You may contact Jeffrey Gordon, Accountant at (202) 551-3866 or Nudrat Salik,
Reviewing Accountant at (202) 551-3692 if  you have questions regarding comments on
the financial statements and related matters.  Please contact Dorine H. Miller, Financial
Analyst at (202) 551-3711 or Brigitte P. Lippmann, Senior Staff Attorney at (202) 551-3713 with any other questions.         S i n c e r e l y ,            Pamela A. Long        A s s i s t a n t  D i r e c t o r   cc: Andrea Cataneo, Esq.  Sichenzia Ross Friedman Ference LLP  61 Broadway, 32nd Floor  New York, NY 10006